Privacy Policy

UK PACT Communications notice and consent

Notice

This notice sets out how Palladium International Limited and the UK Government’s Foreign, Commonwealth and Development Office (FCDO) will use your personal data, and your rights. It is made under Articles 13 and/or 14 of the UK General Data Protection Regulation (UK GDPR). The Data Controller is the Foreign, Commonwealth and Development Office Data Processor is Palladium International Limited (“Palladium”).

You may also find a related privacy statement on Palladium’s website here which contains further information concerning the processing of your personal data undertaken by Palladium. FCDO will be the owner of the data.

Your Data

We will process the following personal data:

Names, business telephone numbers and email addresses, office location and job titles of staff of Implementing Partners, members of the UK PACT mailing list, UK PACT stakeholders, including stakeholders who participate in and benefit from projects in recipient countries, parties who have registered for UK PACT events and staff of organisations applying for funding by both FCDO and Palladium as necessary to deliver the services, run competitive grant application processes, review applications, contact applicants about their applications, award funding and to undertake contract and performance management, as well as communications activities.
Photographs of the above stakeholders may also be processed in accordance with this privacy policy. If so, individuals will be provided with a separate specific consent form for photographs.
Personal opinions of all stakeholders listed above on programme performance, for monitoring, evaluation and learning purposes by FCDO, Palladium, relevant parties within HMG and the UK PACT delivery partners Arup and Social Development Direct, and any relevant sub-contractors. Personal opinions of all stakeholders listed above on UK PACT communications, provided for the purposes on monitoring and improving communications activities.

Purpose

UK PACT (Partnering for Accelerated Climate Transitions) is a flagship programme under the UK’s International Climate Finance (ICF) portfolio. The data we have requested above will be essential to carry out competitive funding rounds for projects, assessment of prospective projects, communications with applicants, funding allocations, project and performance management of Implementing Partners, effective communication with UK PACT stakeholders and external communications activities.

The nature of the processing will include collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, use, disclosure by transmission, dissemination or otherwise making available of data.

The nature of processing will include the storage and use of names and business contact details of staff of Implementing Partners, members of the UK PACT mailing list, UK PACT stakeholders, including stakeholders who participate in and benefit from projects in recipient countries, parties who have registered for UK PACT events and staff of organisations applying for funding as necessary to deliver the services, run competitive application processes, review applications, contact applicants about their applications, award funding and to undertake projects and performance management. All those, whose data is being processed, will be provided with a contact email address for the UK PACT programme.

Lawful basis of processing

The lawful basis for processing your personal data is processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the data controller, such as the exercise of a function of the Crown, a Minister of the Crown, or a government department; the exercise of a function conferred on a person by an enactment; the exercise of a function of either House of Parliament; or the administration of justice. Data will also be processed on the basis of consent: the individual has given clear consent for us to process their personal data for a specific purpose.

Recipients

Your personal data will be shared:

With other UK PACT implementing partners to facilitate coordination, cross-project learning and synergies between projects.
With Palladium’s consultants and sub-contractors, including but not limited to HubSpot, as required to facilitate project management processes, such as the competitive grant application process, due diligence, project monitoring and reporting, or communications processes, such as client relationship management.
With other UK PACT consortium partners Arup and Social Development Direct, as well as their sub-contractors, to facilitate coordination, and learning across the components of UK PACT.
With the UK PACT independent evaluation partner (to be appointed) to facilitate the evaluation of the programme.
With other UK Government Departments or public authorities where necessary as part of the management of this programme, for example to facilitate the competitive grant application process, management of the programme, monitoring and evaluation of projects, knowledge-sharing and cross-programme learning.
- If required to do so by law, for example by court order or to prevent fraud or other crime.
As necessary to deliver the services and inform those on the UK PACT mailing list or who have signed up to UK PACT events about UK PACT, its work and upcoming opportunities.

As your personal data will be stored on FCDO and Palladium IT infrastructure, it will also be shared with our data processors Microsoft.

UK PACT stakeholders will be required to opt in to the UK PACT mailing list to receive updates about UK PACT. UK PACT stakeholders will be provided with a UK PACT contact point in case of any queries. UK PACT stakeholders may unsubscribe from the mailing list at any time.

Implementing Partners will be provided with names and business contact details of FCDO,Palladium, Arup and Social Development Direct staff involved in managing the programme.

What will happen to your personal data?

The Data Controller, Data Processor, their trusted representatives (please see Palladium’s Privacy Policy and UK PACT Privacy Notice for further information relating to disclosures and the recipients of your personal data) alongside the above recipients who will only use your data in the context of this programme.

The Data Controller, Data Processor, and trusted representatives will not:

rent or sell your personal data;
store or disclose your IP address or geolocation to other parties;
publish or disclose your data to any party other than to those mentioned above

As this activity involves the processing of personal data, it is subject to data protection rules as established by European Union: EU Directive 95/46/EC and EU Directive 2002/58/EC, in each case as transposed into domestic legislation of each Member State of the European Economic Area (EEA) and in each case as amended, replaced or superseded from time to time, including without limitation by the EU General Data Protection Regulation 2016/679 of the European Parliament and of the Council (GDPR) and any data protection laws substantially amending, replacing or superseding the GDPR. The United Kingdom General Data Protection Regulation (UK GDPR) is the UK's data privacy law that governs the processing of personal data domestically. It sits alongside the UK Data Protection Act 2018.

Palladium’s sub-contractors HubSpot, hosts the client relationship management system on which your personal data will be held and will encrypt data at rest and in transit.

How do we safeguard your personal data?

The Data Controller, Data Processor and their representatives or agents will strive to implement commercially reasonable physical, administrative and technical safeguards to help us protect the confidentiality, security, and integrity of your personal data and prevent the loss, misuse, unauthorised access, unauthorised interception, or alteration of your information. Your choice to disclose personal data in an email submission or online form is voluntary. Unfortunately, no data transmission over the Internet is 100% secure and we cannot ensure or warrant the security of any such personal data or fully ensure that your private communications and other personal data will not be inadvertently disclosed.

Retention

Your personal data will be kept by us for the duration of the Palladium contract, plus a 12-month retention period. The contract will end in March 2025 but may be extended.

Automated decision making

Your personal data will not be subject to automated decision making.

Your rights

You have the right to request information about how your personal data are processed, and to request a copy of that personal data.
You have the right to request that any inaccuracies in your personal data are rectified without delay.
You have the right to request that any incomplete personal data are completed, including by means of a supplementary statement.
You have the right to request that your personal data are erased if there is no longer a justification for them to be processed.
You have the right in certain circumstances (for example, where accuracy is contested) to request that the processing of your personal data is restricted.
You have the right to object to the processing of your personal data where it is processed for direct marketing purposes.
You have the right to object to the processing of your personal data.

International transfers

As your personal data is stored on FCDO and Palladium IT infrastructure and shared with our data processors Microsoft and Amazon Web Services, it may be transferred and stored securely outside the European Economic Area. Where that is the case it will be subject to equivalent legal protection through the use of Model Contract Clauses where stored by FCDO.

Contact details

The data controller for your personal data is the UK Government’s Foreign, Commonwealth and Development Office (FCDO).

You can contact the Data Protection Officer at the Foreign, Commonwealth & Development Office:

Data Protection Officer
Information Management Department
Information and Digital Directorate
Room WHG.168
Foreign, Commonwealth & Development Office
King Charles Street
London
SW1A 2AH

Email: Data.Protection@fcdo.gov.uk

Telephone: 020 7008 5000

If you have any questions about anything in this notice, or if you consider that your personal data has been misused or mishandled, contact us at data.protection@fcdo.gov.uk.

If you would like to contact the UK PACT team for any questions on data processing, please do so via communications@ukpact.co.uk.

Complaints

If you consider that your personal data has been misused or mishandled you may contact the Information Commissioner, who is an independent regulator. The Information Commissioner can be contacted at:

Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire SK9 5AF
icocasework@ico.org.uk
Telephone: 0303 123 1113
Textphone: 01625 545860

Any complaint to the Information Commissioner is without prejudice to your right to seek redress through the courts.